SFO Guidance Moves Toward Transparency but Offers No Guarantees

One of the most challenging aspects of deciding whether to cooperate with enforcement authorities in a corruption investigation is the uncertainty of the benefits that cooperation will provide in a settlement. In the U.S., the SEC and DOJ have taken significant steps to reassure companies that cooperating will lead to better results. Until now, the U.K. Serious Fraud Office (SFO) had been mostly quiet, but the agency recently took a significant step towards transparency by issuing a document titled Corporate Co-operation Guidance. The Anti-Corruption Report spoke with U.K. practitioners to find out what companies need to know about the new Guidance. In this first article we look at the Guidance’s utility and how it compares to the DOJ’s Corporate Enforcement Policy (CEP). In a future article, we will explore some of the specific cooperation requirements in the Guidance. See “Osofsky’s American Dream for the SFO” (Feb. 20, 2019).

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